2003-2005 - Special Collections - University of Baltimore

esearch techniques, materials, and methodology.
Students are required to prepare
legal memoranda.
TAXA 651 Fundamentals of Federal
Income Tax I (3) Basic concepts in federal
income taxation, including gross income,
exclusions, adjusted gross income, deductions,
exemptions, credits, assignment of
income, identification of the taxpayer, tax
rates, capital gains and losses, 1231 transactions,
depreciation, recapture, and the
alternative minimum tax. Prerequisite course
for all other tax courses except TAXA 650.
TAXA 652 Corporate Taxation (3)
Federal income taxation ofcorporations
and their shareholders with emphasis on
the formation of the corporation, capital
structure, operational alternatives, distributions,
partial and complete liquidations,
personal holding companies, and the
accumulated earnings tax. Formation,
operation, and liquidation of S-corporations
discussed briefly.
TAXA 653 Partnership Taxation (3)
Problems encountered in the formation,
operation, and liquidation ofa partnership
including the acquisition of partnership
interests, compensation of the service partner,
the treatment of partnership distributions,
and problems associated with the
disposition of partnership interests or property
by sale.
TAXA 654 Tax Practice and
Procedure (3) Aspects of practice before
the Internal Revenue Service, including
ruling requests, handling ofaudits, assessment
of deficiencies and penalties, closing
agreements, tax liens, statutes of limitations,
claims for refunds, appeals conferences
and practice before the u.S. Tax
Court, U.S. District Courts, Claims Court,
and appellate courts. Also includes analysis
of the problems encountered in parallel
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civil and criminal proceedings, problems
involving government investigatory powers
and taxpayer rights and privileges.
TAXA 655 Tax Policy (3) Study of the
evolution and structure of the federal
income tax system from a public policy
perspective with a focus on legal, economic,
social, and practical considerations.
Alternatives, including current legislative
proposals, ate considered. Students prepare
a paper on a tax policy issue approved by
the professor.
TAXA 660 Estate and Gift Taxation (3)
Basic principles of federal estate and gift
taxation, including computation of the taxable
estate, inter vivos transfers, transfers in
contemplation of death, transfers with
retained interests or powers, joint interests,
life insurance proceeds, property subject to
powers ofappointment, the marital deduction,
and the unified credit.
TAXA 662 Foreign Taxation (3) Analysis
of the federal income tax provisions applying
to U.S. inbound and outbound transactions
and investments. Course covers U.S.
resident status, source-of-income rules,
graduated tax on effectively connected
income, withholding tax on FDAP income,
branch profits tax, FlRPTA, tax treaties,
foreign tax credit, foreign earned income
exclusion, Subpart F, and transfer pricing.
TAXA 663 Qualified Pension and Profit­
Sharing Plans (3) An introduction to pension
and profit-sharing law with particular
emphasis on Tide 2 (IRS) of ERISA.
Course is geared toward understanding all
of the pension and profit-sharing rules that
must be met for plan qualification, with
emphasis on qualified plan planning for
both incorporated and unincorporated
forms of business.